Uniform Guidance is the largest regulatory revision research administration has seen in recent years. Grants and contracts awarded by the federal government to Radford University are subject to administrative requirements, cost principles, and audit requirements. The new consolidated guidance replaces three Office of Management and Budget (OMB) Circulars governing those requirements applicable to universities and other related institutions.
The purpose of Uniform Guidance is to reduce the regulatory and administrative burden on funding recipients, as well as diminishing the risk of waste, fraud, and abuse. New and incrementally-funded awards issued on or after December 26, 2014 are subject to Uniform Guidance.
Uniform Guidance is broken down into the following subparts:
Subpart A |
200.000 – 200.99 |
Acronyms and Definitions |
Subpart B |
200.100 – 200.113 |
General Provisions |
Subpart C |
200.200 – 200.212 |
Pre- Award Requirements |
Subpart D |
200.300 – 200.345 |
Post Award Requirements |
Subpart E |
200.400 – 200.475 |
Cost Principles |
Subpart F |
200.500 – 200.521 |
Audit Requirements |
Specficially, for managing federal grants and contracts, the following subparts are very important to use as general guidance for grant accounting.
Supplies
200.314
If there is a residual inventory of unused supplies exceeding $5,000 in total aggregate value upon termination or completion of the project or program and the supplies are not needed for any other Federal award, the non-Federal entity must retain the supplies for use on other activities or sell them, but must, in either case, compensate the Federal Government for its share. This is not a new requirement and existed under Circular A-110, C.35(a).
Subrecipient Monitoring
200.331
Institutions are required to perform a risk review of subrecipients prior to issuing a subaward. Potential items for review: financial and performance reports, audit deficiencies, indirect cost rate, training, and on-site visits.
Closeout
200.343
Closeout reports are to be submitted no later than 90 calendar days after the end date of the performance period.
Administrative and Clerical Salaries
200.413
Administrative and clerical staff should normally be treated as indirect (F&A) costs. Direct charging of these costs may be appropriate only if all of the following conditions are met:
Computing Devices
200.453
Computers under the university capitalization threshold may be charged as direct costs if they are essential and allocable, but not solely dedicated to, the performance of a federal award.
Publiation and Printing Costs
200.461
Page charges for professional journals are allowable when they report work on an award and the journal levies charges impartially on all items published by the journal (whether or not under a federal award). The costs of publication or sharing of research may be charged even if incurred after the end date of the award but before award closeout.